Website Privacy Statement
An Post (“we” or “us”) will collect and process your Personal Data, and other information in relation to your dealings with us, in connection with this Website. This Privacy Statement explains how we will manage your Personal Data obtained via this Website, why we use it, and how you may contact us. Separate privacy statements may apply to specific products or services provided to you by the An Post Group.
Where we need to process your Personal Data in connection with your application for a product or service provided by the An Post Group, or where we have a legal obligation to collect certain Personal Data relating to you (for example, in order to comply with our AML obligations), we will not be able to provide you with the product or service which you have requested if you do not provide this information to us.
Types of Information we Collect through this Website
means any information which the An Post Group has or obtains or which you provide through this Website, such as your name, address, email address, telephone number(s) and date of birth, from which you can be directly or indirectly personally identified, and includes information such as identification IP addresses, cookie identifiers and online identifiers.
We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to our Website. This Non-Personal Data
comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of our Website. We collect this information to help us monitor traffic and enhance your experience of our Website.
How we obtain your Information via this Website
We will obtain some of your Personal Data directly from you, such as when you complete an application form, use Track & Trace or where you choose to give us Personal Data through online feedback forms.
We may also obtain some of your information indirectly, from a variety of sources, where we provide you with postal or other services. How we use your personal information in connection with our postal and other services is explained in our privacy statement.
Why we hold and how we use your Information
We will use your Personal Data, but only to the extent necessary:
- to contact you if required in connection with, or to deal with queries, complaints or suggestions you make to us via this Website;
where you have otherwise consented to our use for a particular purpose, such as for marketing.
If you do give your consent for us to use your Personal Data for a particular purpose, you have the right at any time to withdraw your consent to our future use of your Personal Data for some or all of those purposes by writing to us at the address set out under “Contact Us” below;
- where our use is for a legitimate purpose of the An Post Group, including:
- for day to day operational and business purposes, including board and group reporting and management purposes;
- taking advice from our external legal and other advisors;
- to help us improve our services and systems, and to improve your experience on our web and online services;
- to undertake market research, statistical and product development analyses;
- to provide you with information in relation to the An Post Group and certain selected third parties, where we are permitted to do so (please see “Marketing preferences” below for further information); and
- in deciding what marketing information to send to you and to make it more relevant to you.
- where necessary to establish, exercise or defend An Post Group legal rights or for the purpose of legal proceedings; and
- for such other purposes as were notified to you at the time you provide the information to us.
When we disclose your Information
We will not disclose any of your Personal Data to any third party, except as outlined above and / or as follows:
- where we need to provide your Personal Data to counterparties to transactions entered into by you;
- to anyone providing a service to us or acting as our agents, which may include either companies within the An Post Group or third party service providers, on the understanding that they will keep your Personal Data confidential;
- where we need to share your Personal Data within the An Post Group or with our auditors, and our legal and other advisors; and
- if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
Recipients of your Personal Data
In any case where we share your Personal Data with a third party data controller, the use by that third party of your Personal Data will be subject to the third party’s own privacy policies.
Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with your use of the An Post Websites where you have explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in Ireland.
However, some transfers may be to countries which do not have equivalent protections, and in that case, we will use reasonable efforts to implement contractual protections for the Personal Data. While this will not always be possible where we are required to transfer the Information in order to comply with and perform our contract with you or where we have a legal obligation to transfer the Personal Data, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
Security of data
An Post takes its security obligations in respect of your Personal Data seriously under applicable data protection laws to prevent unauthorised access to, or alteration or destruction of Personal Data in our possession.
Retention of your Personal Data
We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.
If Personal Data is disclosed to us by you in connection with a general enquiry through the An Post Websites, for example where you enter your details into a website form or you send us an email, that Personal Data will be retained for a period of 13 months.
Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, we (or our service providers on our behalf) will hold this information for a period of seven years, unless we are obliged to hold it for a longer period under law or applicable regulations.
Your rights in relation to your Personal Data
Updating and correcting your Personal Data
If we hold incorrect Personal Data about you, you have the right to have your Personal Data amended. While we will use reasonable efforts to keep your Personal Data up to date, you will need to notify us without delay in the event of any change in your personal circumstances, so that we can keep your Personal Data up to date.
You can update your Personal Data by writing to the Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or email@example.com
1. Your name and address; and
2. A description of the specific Personal Data you wish to be rectified.
Right of erasure
You have the right in some circumstances to have your Personal Data, which we hold, erased. If you request an erasure of your Personal Data, all your data will be erased subject to the following important notice.
We will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your Personal Data in order to comply with a legal obligation, or if your Personal Data is necessary to establish, exercise or defend our or An Post Group legal rights or for the purpose of legal proceedings.
To request that we erase your Personal Data which we hold please send your request to us in writing at Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or firstname.lastname@example.org
1. Your name and address; and
2. A description of the specific personal data you wish rectified.
Right of Access
You have a right to be given a copy of your Personal Data on request, subject to certain exceptions. Please note that we have the right to require that you identify yourself before we will respond to any access request. For more information, see our Data Access Policy
Your Other Rights
You also have the right, in certain circumstances, to request restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data can be obtained by writing to us at the address set out under “Contact Us” below.
In any case where we rely on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to us at the address set out under “Contact Us” below.
Where we rely on a legitimate purpose of ours or of a member of the An Post Group or a third party recipient of your Personal Data, in order to use and disclose your Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, we will cease to use and process your Personal Data for that purpose, unless we can show there are compelling legitimate reasons for us to continue or we need to use your Personal Data for the purposes of legal claims.
In limited circumstances, you may also have the right to data portability in respect of certain of your Personal Data, which means you can request that we provide it to you in a structured, commonly used and machine-readable format, or transmit it to your third party nominee where this is technically feasible.
You have the right to lodge a complaint about our processing of your Personal Data with the Data Protection Commissioner at email@example.com
Where you request Information about the An Post Group. Where you choose to give us Personal Data, such as where you enter your details into our Website forms, we will use this information to send you an acknowledgement e-mail and to provide you with the information you have requested. We may also send you subsequent emails, SMS messages or contact you by phone to follow up on your initial query. Where you have agreed, we may also contact you in relation to other marketing (see Other Marketing by An Post).
Other Marketing by An Post
Where you have agreed via this Website to receive marketing from the An Post Group of companies and select third parties, we will use this information to contact you with news and special offers from the An Post Group of companies and select third parties.
An Post Group of Companies:
GeoDirectory, Post Insurance, PCI, PostPoint, PrintPost, Prize Bonds, BillPost and Air Business.
Making Marketing Relevant to You
Opting out of Marketing
You can change your marketing preferences at any time by contacting Marketing Department, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2. Each time we send you marketing information, we will give you the option to change your mind about receipt of marketing (eg SMS: text STOP).
Use of Non-Personal Data from our Website
We use the Non-Personal Data gathered from visitors to our Website in an aggregate form to understand the demographics of the users of our Website, to help us better design and organise our Websites and mobile applications. We use these analytics tools to assist in gathering and analysing Non-Personal Data for the reasons described above. Our analytics solutions may also collect your IP address as part of this analysis. No other form of Personal Data is gathered by these analytics services. Except as explained above in relation to your IP address, by simply visiting our Website, you do not disclose, nor do we collect, Personal Data on you. The information collected about your visit may be limited to technical data which is used for administrative and statistical purposes, for example whether you reached the Website using a search engine or if you clicked a link on another website; the type of web-browser you used; or the type of device you used to access the Internet. We will use this information to help us to improve our Website. We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of the An Post Website. For example, we may inform third parties regarding the number of unique visitors to the An Post Website, the demographic breakdown of users of our Website, or the activities that visitors to the An Post Website engage in while online. The third parties to whom we may provide this information may include our Website design, development, digital, support and hosting contractors.
Review and Update
This Policy will be reviewed and updated annually by the An Post Data Protection Officer or more frequently if necessary to ensure that any changes to An Post’s organisation structure and business practices are properly reflected in this Policy. Any queries or complaints regarding our use of the Personal Data and / or the exercise of your individual rights should be addressed to the Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or firstname.lastname@example.org.
Last Updated July 2019